Board of Commissioners of Lowndes County v. Mayor and Council of the City of Valdosta

Summary

The Supreme Court of Georgia held that sovereign immunity does not bar individual-capacity claims for prospective declaratory and injunctive relief against state officials alleged to be acting beyond their lawful authority. The real-party-in-interest limitation is narrow and generally applies when the requested relief would affect the State's real property or contractual obligations, not merely because it may indirectly affect state operations or expenditures. The court reversed the dismissal of the County's claims and left other potential issues, including whether the defendants acted without lawful authority and whether the proper defendants were named, for the lower court.